If You Sell into the EU, Accessibility Became an Export Requirement in June 2025

I have raised this with Japanese companies selling into Europe and it almost never lands. GDPR caused a panic here. This one went largely unnoticed. The application date has already passed.

If your company is in scope, you are either compliant or you are not. There is no "under review" status in the law.

What the act is

Directive (EU) 2019/882, known as the European Accessibility Act. Adopted in April 2019, with Member States required to apply their measures from 28 June 2025.

It covers e-commerce, consumer banking services, e-books, passenger transport services, telecommunications, and the equipment used to reach them, including payment terminals and self service machines.

For a website or an app, meeting it in practice means the accessibility outcomes of WCAG 2.1 Level AA, referenced through the harmonised European standard EN 301 549.

The part Japanese companies miss

Scope is not determined by where a company is established. It is determined by whether you are placing products or services on the EU market.

If you sell to consumers in the EU, you are in scope. Being headquartered in Tokyo or Osaka does not exempt you, in exactly the way it did not exempt anyone from GDPR.

I have heard "we have no EU entity, so it does not apply to us" more than once. That is not the test.

Which exemptions actually help

Before anyone panics, check the carve outs.

Microenterprises providing services are exempt from the service side requirements under Article 4(5). That means fewer than 10 employees and annual turnover or balance sheet total at or below two million euro. It applies to services only, not to the product side, and the exemption disappears as soon as you cross the thresholds.

The transitional measures are in Article 32. Service providers may continue providing services using products that were lawfully in use before 28 June 2025, through a transitional period ending 28 June 2030. Service contracts agreed before 28 June 2025 may run until they expire, capped at five years. Self service terminals already in use may continue to the end of their economically useful life, up to twenty years.

Read those carefully. They protect equipment and contracts you already have. They do nothing for the new site you are launching next year or the app you have not shipped yet.

Japan's own obligation also changed in 2024

Around the same time, one thing changed domestically.

From 1 April 2024, the revised Act on the Elimination of Discrimination against Persons with Disabilities made providing reasonable accommodation a legal obligation for private businesses. Public bodies had carried that duty from the start. Private companies had been asked to make an effort.

Two misreadings are common here.

The first is treating it as an employment rule. It is not limited to employees. It covers the users of your products and services, which for most companies means customers.

The second is confusing it with conformance to a technical standard. JIS X 8341-3 has not become mandatory for private companies. What is mandatory is that when a person with a disability asks you to remove a barrier, you engage with them and work out a solution unless the burden is genuinely excessive. In practice, a company whose product cannot be used with a screen reader has made that conversation both more likely and much harder to resolve.

How far to take the technical standard itself is a separate question, covered in how far accessibility work should actually go.

Why retrofitting costs so much

Adding accessibility later is close to a rebuild. Designing for it costs almost nothing. That asymmetry is the whole argument and it is unintuitive, so here is the mechanism.

Almost every accessibility failure is decided very early and very cheaply. Whether the palette has sufficient contrast. Whether form fields have real labels. Whether an interactive element is a real button or a styled div. Whether the heading structure describes the content. Whether the main task can be completed with a keyboard.

None of those cost anything at the moment they are decided. They are a designer picking a colour and a developer picking a tag.

By the time the product exists, each of those decisions has been made hundreds of times, inconsistently, across a codebase. That is why the remediation quote makes people angry. Nobody is overcharging. You are being asked to pay for a year of small decisions in a single invoice.

A second language works identically, which is why I raise both in the same meeting. Deciding at the start to ship in Japanese and English is nearly free. Adding English two years later breaks every layout that was built around Japanese text lengths.

What to do this quarter

If you sell into the EU, start with scope. Which of your services are covered, does the microenterprise exemption apply, and does any transitional provision buy you time. A couple of days of work, and it tells you whether this is urgent or merely important.

Then audit one thing rather than everything. Take the single path that makes you money and run it end to end. Keyboard only. Then with a screen reader. Then at 200% zoom. You do not need a vendor, and you will learn more in an afternoon than a report will tell you.

Then fix decisions, not pages. Wrong contrast lives in a token, not on a page. Buttons that are not buttons live in a component. Fixing the source of a class of errors is the only way to stop the count growing while you work.

Then put it in the definition of done for new work. This is the step everyone skips and the only one that changes the trajectory.

For the Japanese obligation, start with process rather than code. Someone has to be able to receive a request, understand it and answer it. If a customer asks for an accommodation and the email sits unread because nobody owns it, your HTML is not the biggest problem.

One more reason

As of September 2025, 36.19 million people in Japan are 65 or over, which is 29.4% of the population. That is the highest share among the 38 countries with populations above 40 million, ahead of Italy at 25.1% and Germany at 23.7%.

The design responses to ageing eyes and hands are nearly identical to accessibility work. Larger touch targets, higher contrast, text that scales, forms that forgive mistakes.

So Japanese companies sit in an unusual position, where the domestic demographic argument and the European legal argument point at exactly the same work. Noticing that before a remediation quote arrives is considerably cheaper than noticing after.

References

• Directive (EU) 2019/882, the European Accessibility Act. Application from 28 June 2025 (Article 31), microenterprise exemption for services (Article 4(5)), transitional measures (Article 32)
• EN 301 549, the harmonised European standard for ICT accessibility, which incorporates WCAG 2.1 Level AA for web content
• Cabinet Office of Japan, 令和6年4月1日から合理的配慮の提供が義務化されました and the leaflet PDF
• Statistics Bureau of Japan, 統計からみた我が国の高齢者, 14 September 2025